Understanding Article 4(3) of Regulation (EU) 2019/1020: What Non‑EU Sellers Must Know
If you're a manufacturer, brand owner, or online seller based outside the European Union, selling into the EU market comes with legal responsibilities — and one of the most important is compliance with Regulation (EU) 2019/1020 on market surveillance and product compliance.
What Article 4(3) Says
Under Article 4(3), products covered by this Regulation can only be placed on the EU market if there is an economic operator established in the Union who performs specific compliance tasks. If the manufacturer is based outside the EU, they must appoint:
- An EU-based importer, or
- An authorised representative, or
- A fulfilment service provider (e.g. EU-based warehouse handling storage, packaging, or shipping).
EaseCert | GPSR Compliance can act as your EU Responsible Person under Article 4(3), ensuring you meet all regulatory obligations.
Responsibilities of the EU-Based Operator
The designated operator must:
- Verify the EU Declaration of Conformity or Declaration of Performance
- Ensure technical documentation is available to market surveillance authorities
- Cooperate with authorities on compliance matters
- Take corrective action if a product is unsafe or non-compliant
- Ensure traceability, including maintaining contact details and product identifiers
Failing to appoint such an operator may result in customs blocking, marketplace delisting, or withdrawal of your products from the EU market.
Scope of the Requirement
Article 4 applies to many consumer products, including electrical equipment, toys, PPE, machinery, measuring instruments, and others listed in Annex I. If your products fall under any of these categories, you must appoint a compliant EU-based operator to avoid non-compliance issues.
How EaseCert Can Help
At EaseCert, we support non-EU brands, small businesses, and e-commerce sellers by serving as your designated economic operator under Article 4(3). Our services include:
- Fast onboarding and document review
- Secure technical file storage
- Ongoing compliance support
- EU address and contact for labeling
- Assistance with market surveillance inquiries and cooperation
We also support compliance with the General Product Safety Regulation (EU) 2023/988, which updates the framework governing nearly all consumer goods in the EU.
Need Help Navigating Article 4(3) or GPSR?
Contact us at info@easecert.com to learn how we can support your EU compliance strategy.